55. In the context of prisons72 in which persons with disabilities are deprived of their liberty, reasonable accommodation not only involves adapting the physical environment73 as a general obligation (accessibility) for the entire prison population affected by physical constraints, as in the present case, but also addressing particular cases, with specific measures designed to make effective the rights of persons with disabilities enshrined in international human rights law, including all measures aimed at guaranteeing the right to health. 56. Regarding the reasonable accommodation required to ensure Mrs. Chinchilla’s right to health, the Inter-American Court considered that the State had the obligation to ensure accessibility to persons with disabilities deprived of their liberty, in accordance with the principle of non-discrimination and the interrelated elements for the protection of health, namely, availability, accessibility, acceptability and quality, including reasonable accommodation in the prison, to enable her to live with the greatest independence possible and in equality of conditions with other persons deprived of their liberty.74 57. In this regard, I consider it very important to distinguish between accessibility for persons with disabilities (supra. paras. 52-54) and the accessibility of the right to health to a person with disabilities. While the first refers to a more general sense of adaptability in the terms of the CRPD,75 the second implies, in specific cases, the implementation of reasonable accommodation that would enable a person affected by a physical, mental, intellectual or sensory impairment, to enjoy and make effective their right to health. This, in the terms of General Comment No. 14 of the ESCR Committee, is related to accessibility based on non-discrimination, since health care goods and services must be accessible de facto and de iure to the most vulnerable and marginalized sectors of the community, without In its analysis of Article 9, paragraph 1, the Committee on the Rights of Persons with Disabilities, in General Comment No. 2, requires States Parties to identify and eliminate obstacles and barriers to accessibility to, inter alia: a) Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces and b) Information, communications and other services, including electronic services and emergency services. Other indoor and outdoor facilities mentioned above should include, inter alia … [prisons]. Cf. Committee on the Rights of Persons with Disabilities, General Comment No. 2, Article 9: Accessibility, CRPD/C/GC/2, May 22, 2014, para. 17. 72 On the physical aspects of accessibility, the Inter-American Convention for the Elimination of All Forms of Discrimination Against Persons with Disabilities establishes that to achieve the objectives of the Convention, the States Parties undertake to adopt measures to ensure that new buildings, vehicles and facilities constructed or manufactured within their respective territories facilitate transportation, communications, and access by persons with disabilities. And, in addition, all measures to eliminate, to the extent possible, architectural, transportation and communication obstacles to facilitate access and use by persons with disabilities (Article III .1 b and c). For its part the CRPD, recognizes the importance of ensuring accessibility to the physical environment by adopting measures to ensure access to buildings, public roads, transportation and other outside facilities such as schools, housing, medical facilities and workplaces. (Article. 9.1.a) 73 Cf. Case of Chinchilla Sandoval v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of February 29, 2016, Series C No. 312, para. 215. 74 The distinction between accessibility according to the CRPD, and the accessibility of the right to health according to the ESCR Committee, did not eliminate the State’s obligation to create goods, buildings and services of an accessible nature in advance. In other words, in first instance, the States must provide accessible transportation even before a person with disabilities is deprived of liberty, as in this particular case. However, when this measure has not been adopted in advance, the adaptation of the means of transport for ambulatory treatment, constitutes a specific situation, since not all disabled persons deprived of liberty would need to travel outside the detention center to receive ambulatory treatment. 75 21